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Filing # 99804602 E-Filed 12/04/2019 04:09:41 PM
19-0172 IN THE CIRCUIT COURT OF THE 14
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CIVIL DIVISION
CASE NUMBER: 19004413CA
MARGARITA VENCIUS-REDD,
Plaintiff,
vs.
CASTLE KEY INSURANCE COMPANY,
Defendant.
/
NOTICE OF SERVING FIRST SET INTERROGATORIES
COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the
undersigned counsel and hereby propounds to Defendant CASTLE KEY INSURANCE
COMPANY, the attached Interrogatories.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was served
on the Defendant along with the Complaint and Summons this 4th day of December, 2019.
CORREDOR & HUSSEINI, P.A.
Maria E. Corredor, Esq.
FBN: 76619
José C. Leén, Esq.
FBN:; 125553
3905 N.W. 107th Avenue
Suite 502
Telephone: 305-670-1880
Facsimile: 305-670-1985
Email: jleon@chslaw.net
Email: service(@corredorhusseinilaw.com
Attorneys for Plaintiff(s)19-0172 IN THE CIRCUIT COURT OF THE 147
JUDICIAL CIRCUIT IN AND FOR
BAY COUNTY, FLORIDA
CIVIL DIVISION
CASE NUMBER:
MARGARITA VENCIUS-REDD,
VS.
Plaintiff,
CASTLE KEY INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S FIRST SET OF INTERROGATORIES
COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the
undersigned counsel, and hereby propound the following interrogatories to Defendant CASTLE
KEY INSURANCE COMPANY, to be answered in writing, under oath:
DEFINITIONS
. “Plaintiff(sy” and “insured(s)” shall refer to MARGARITA VENCIUS-REDD,
his/her/their agent(s), employee(s), representative(s), attorneys and/or anyone else acting
on their behalf.
. “Defendant,” “you,” and “your” shall refer to CASTLE KEY INSURANCE COMPANY,
individually or any representatives, employees, officers, directors, agents, or attorneys or
other personas acting or purporting to act on behalf of CASTLE KEY INSURANCE
COMPANY.
. The “Complaint” means the Complaint filed by the Insured(s) in this action.
. The “home,” “property,” or “insured property” shall refer to the property referenced in
the Complaint and its attachments.
. The term “policy” shall refer to the insurance policy referenced in the Complaint and its
attachments.
. The “Date of the Loss” shall refer to the date the insured property sustained the damage
for which the Complaint was filed.
. The term “representative” as used herein with regard to a person or entity means and
includes any natural person, individual, proprietorship, partnership, corporation,
association, organization, join venture, firm, other business enterprise, governmentalbody, each and every present and former director, officer, partner, employee, agent,
independent consultant or expert or other person (including attorneys), such as friends,
relatives and spouse acting or purporting to act on behalf of the person or entity,
. “Person(s)” shall refer to a natural person, an individual, firm, association, partnership,
joint venture, corporation, trust and estate, or other form of legal or business entity,
public or private.
“Document(s)” shall refer to and all written recorded, or graphic matter, however
produced or reproduced, of every kind and description, hether produced internally or
received from outside sources, including without limiting the generality of the foregoing,
and all originals, copies, and drafts, of all papers, books, letters, correspondence,
memoranda, catalogs, warranties, minutes of meetings, facsimiles transfer lists,
shareholder lists, opinion letters, letters of understanding, letters of intent, private
placement memoranda, SEC Form 504 Offer Statements, offering statements or circulars,
memoranda of telephone conversations, telegrams, photographs, prospectus, drawings,
sketches, feasibility studies, interoffice communications, licenses, testing reports,
laboratory reports, agreements, ledgers, books of account, summaries, computer print-
outs, proposals, suggestions, legal pleadings, bills of sale, indemnity agreements, security
notebooks., calendar, appointment books, diaries, agendas, time sheets, log, transaction
files, credit reports, notations, notes, minutes of meetings, sound records, photo records,
or tale recordings or other data compilations from which information can be obtained,
any transcriptions thereof, bulletins, circulars, press releases, notices, instructions,
advertisements, work assignments, film videotapes, film negatives, research, articles,
treatises, and including all attachments and enclosures thereto. Documents shall also
include matters stored in an electronic medium, such matters being, among others, voice
mail messages and filed, backup voice mail files, email messages and files, word
processing documents, spreadsheets, presentation documents, graphics, animations,
images, instant messages and/or instant message logs, backup email files, deleted email
data files, program files, backup and archived tapes, temporary files, system history files,
website log files, cache files, cookies, and other electronically recorded information.
Documents also means all documents of the class requested and includes all documents
in the immediate possession and control of the deponent and or all documents that can be
obtained from the other persons subject to the direction and control of the deponent,
including but not limited to, agents, employees, officers, directors, attorneys, accountants,
subcontractors and consultants.
Electronic documents shall also include matters described as accurate data, deleted data,
backup data, metadata, migrated data, replicate data, residual data, and legacy data.
. The term “concerning” means relating to, referring to, describing, evidencing and /or
constituting.
. The conjunctions “and” and “or” shall be interpreted in every instance as meaning
“and/or.”. The term “referring (to)” or “relating (to)” shall mean setting forth, pertaining to,
memorializing, constituting, embodying, discussing, analyzing, reflecting, showing,
disclosing, averring to, comprising, evidencing, or otherwise concerning.
. As herein used, the singular shall include the plural.
. The word “any” shall be interpreted as to include the word “all” and the word “all” shall
be interpreted as to include the word “any.”
The term “communication” shall refer to any transmission of information by any means,
including without limitation, by spoken language, electronic transmission of data or any
other means, any copies of written information received by the person or entity
responding to this request, even if such person or entity is not the primary or direct
addressee of such written information.
. “Locate” or “location” shall mean to state the present whereabouts of each Document and
to identify the persons having possession, custody, or control thereof
. “Date” shall mean the exact day, month, and year, if ascertainable, or if not, the best
approximation (including relationship in time to other events).
Identify, when used in reference to:
a. an individual, shall mean to state their full name, present or last known address
(designating which) and present or last known employment, position, business
affiliation (designating which) including job title and employment address; or
such other information sufficient to enable Plaintiff to identify the person;
b. an entity, shall mean to state tis full name and preset or last known address
(designating which), the legal form of such entity, and the residence address, job
title, and business address for its Chief Executive Officer.
c. a document, shall mean to state the title (if any), date , author, sender, recipient,
type of document, or some other means of identifying it, a summary of its
contents and its present location and custodian;
d. an oral transaction or oral communication, shall mean to state the date and place
thereof, the author and the recipient of the communication, and a sufficient
summary of the contents of the communication to indicate the nature and
substance.
. “Identify,” when used in any context not addressed above, shall mean to describe the act,
word, situation, event, conduct, and course of action of any nature whatsoever, including
without limitation any failure to act, to engage in any conduct or to pursue any course of
action, as fully as possible and identify each way in which said act, word, situation, event,
conduct, or course of action was recorded.INSTRUCTIONS
A. If any interrogatory requests information about persons that no longer work for you,
please provide his/her last known home address and phone number.
B. These interrogatories are continuing so as to require the filing of subsequent answers
promptly in the event that defendant, by or through any of their agents, counsels or other
representatives, learns additional facts relevant to any answers not set forth in their
answers to these interrogatories or discovers that any information given in an answer or
answers is erroneous.
C. For each and every answer to these interrogatories:
a. Identify each and every person who participated in supplying information and/or
drafting your response or any part thereof; and
b. If the answer to any of these interrogatories was made by referring to or reviewing
any documents, identify each and every document referred to or reviewed and the
interrogatories in connection with which they were used.
D. As used in these interrogatories, the singular shall be deemed to include the plural, and
the plural to include to the singular, so as to make the interrogatory inclusive rather than
exclusive.
E. Where an interrogatory contains a general question followed by a specific question, the
specific question is to be read and interpreted as requesting additional information, not as
limiting the general question.
F. Whenever an interrogatory calls for information that is not available to you in the form
requested, but which is available in another form or can be obtained at least in part from
other data in your possession, so state, and either (a) supply the information requested in
the form in which it is available, or (b) supply the data from which the information
requested can be obtained.
G. If you claim a privilege with respect to information pertaining to any document that you
are asked to identify or describe in these interrogatories, furnish a list signed by counsel
giving the following information with respect to each such document:
a. The title of the documents;
b. The nature of the documents, e.g. interoffice memorandum, correspondence,
report, etc.
c. The identity of the sender and identity of the recipients of the document;
d. A statement of the basis from which the privilege is claimed and a summary of
the subject matter of the document in sufficient detail to permit the Court to rule
on the propriety of the claim of privilege; and
e. The paragraph number of the interrogatory to which the document is responsive
or otherwise pertains;
H. If you contend that it would be unreasonably burdensome to obtain and provide all of the
information called for in response to any one of these interrogatories or any subpart
thereof, then in response to the appropriate interrogatory or subpart:L
a. Set forth all such information that is available to you without undertaking what
you contend to be an unreasonable burden;
b. State with particularity the grounds on which you contend that additional efforts
to obtain such information would be unreasonably burdensome; and
c. Describe with particularity the efforts made by you to secure such information,
including, without limitation, the identity of all persons consulted, and filed,
records, and documents reviewed, and the identity of each person who
participated in fathering such information, including the duration of time spent
and nature of work done by each person.
Interrogatories calling for numerical or chronological information shall be deemed, to the
extent that precise figures or dates are not known, to call for estimates.
You may, in lieu of identifying any Document or written documentation, attach a true and
correct copy of each Document as en exhibit to the answers to these interrogatories. On
each occasion in which you choose to attach a Document as your answer to an
interrogatory, identify the portion of the Document that answers the interrogatory.
. Identify each Document produced pursuant to an interrogatory by the paragraph number
of the interrogatory in response to which it is produced and by the file from which the
document was produced.
If any of the information furnished in an answer to all of part of any interrogatory is not
within your personal knowledge, identify each person who has personal knowledge of the
information furnished in such answer and each person who communicated to you any
part of the information furnished.INTERROGATORIES
1, Identify each person who prepared answers to these interrogatories or supplied and/or
provided information to you used to prepare your answers to these interrogatories by
stating each person’s name, current business address, telephone number, and relationship
to the Defendant.
ANSWER:
2. Identify all individuals and/or entities, including the desk adjuster/internal claims
adjuster, field adjuster/independent adjuster, forensic engineer, general contractor,
examiners, supervisors, and estimators, that have worked on Plaintiff's claim by stating
their telephone numbers, current business addresses, and their involvement in Plaintiff's
claim.
ANSWER:3. Identify all inspections, reviews, and/or investigations that you conducted of the insured
property, from the date of loss through the current date, by stating the dates and reasons
for the inspections/reviews/investigations, and the names and business address of the
persons present.
ANSWER:
4. Identify all reports, photographs, or other documents made at each inspection, review,
and/or investigation that you conducted of the insured property, from the date of loss
through the current date, and state the current location of each said report, photograph, or
document.
ANSWER:5. If your company’s underwriting department inspected Plaintiffs property as a condition
to insuring the property or renewing said insurance, state the names and business
addresses of the individuals or entities that performed said inspections and the dates of
said inspections.
ANSWER:
6. If you prepared a payment letter or explanation of payment to Plaintiff, identify all the
documents that you relied upon in preparing said letter.
ANSWER:7, Please identify by claim number all claims associated with the loss referenced in the
Complaint.
ANSWER:
8. Identify, by name, business address, and phone number, each person that is or has been
responsible for determining and/or analyzing on your behalf how the policy of insurance
that you used for the insured property applies to the claim for coverage at issue in this
lawsuit.
ANSWER:9.
10.
Identify all estimates of damages regarding the insured property, from the effective date
of the policy of insurance through the date of your response to this interrogatory request,
by specifying the names of all persons who prepared the estimate, the date in which such
estimate was prepared, the year of pricing used, the source of pricing, and the reason that
the estimate was prepared.
ANSWER:
Without referring to any court pleading, please state with specificity the basis for all of
your affirmative defenses. Please specify all facts and identify with specificity all
documents supporting said affirmative defenses.
ANSWER:11. Please state with specificity how the amount of depreciation was calculated in the instant
matter. Furthermore, please refer to any and all documentation and/or facts which support
the amount of depreciation claimed.
ANSWER:
12. Please state any condition precedent and any condition subsequent to Plaintiffs claim
that you contend have not been fulfilled by the Plaintiff.
ANSWER:
13. Defendant claims that Plaintiff failed to submit documents or information, or failed to
comply with a request, including requests for reinsertion of the property or for the
Plaintiff to submit to a recorded statement. Please state which documents, information, or
other request Plaintiff allegedly failed to comply with. For each such request, please state
by date and in what form that request was made.
ANSWER:JURAT PAGE
Dy ene» being duly sworn upon oath, state that the
foregoing Answers to Interrogatories are true and correct.
STATE OF FLORIDA )
COUNTY OF 5
The foregoing instrument was acknowledged before me, this
a cen? 2019 by |
known to me or, who has produced ___
and who did take an oath.
day of
__ who is personally
__. a8 identification
NOTARY PUBLIC
My Commission Expires:
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Filing # 99804602 E-Filed 12/04/2019 04:09:41 PM 19-0172 IN THE CIRCUIT COURT OF THE 14 JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION CASE NUMBER: 19004413CA MARGARITA VENCIUS-REDD, Plaintiff, vs. CASTLE KEY INSURANCE COMPANY, Defendant. / NOTICE OF SERVING FIRST SET INTERROGATORIES COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the undersigned counsel and hereby propounds to Defendant CASTLE KEY INSURANCE COMPANY, the attached Interrogatories. CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing was served on the Defendant along with the Complaint and Summons this 4th day of December, 2019. CORREDOR & HUSSEINI, P.A. Maria E. Corredor, Esq. FBN: 76619 José C. Leén, Esq. FBN:; 125553 3905 N.W. 107th Avenue Suite 502 Telephone: 305-670-1880 Facsimile: 305-670-1985 Email: jleon@chslaw.net Email: service(@corredorhusseinilaw.com Attorneys for Plaintiff(s)19-0172 IN THE CIRCUIT COURT OF THE 147 JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION CASE NUMBER: MARGARITA VENCIUS-REDD, VS. Plaintiff, CASTLE KEY INSURANCE COMPANY, Defendant. / PLAINTIFF’S FIRST SET OF INTERROGATORIES COMES NOW, Plaintiff MARGARITA VENCIUS-REDD, by and through the undersigned counsel, and hereby propound the following interrogatories to Defendant CASTLE KEY INSURANCE COMPANY, to be answered in writing, under oath: DEFINITIONS . “Plaintiff(sy” and “insured(s)” shall refer to MARGARITA VENCIUS-REDD, his/her/their agent(s), employee(s), representative(s), attorneys and/or anyone else acting on their behalf. . “Defendant,” “you,” and “your” shall refer to CASTLE KEY INSURANCE COMPANY, individually or any representatives, employees, officers, directors, agents, or attorneys or other personas acting or purporting to act on behalf of CASTLE KEY INSURANCE COMPANY. . The “Complaint” means the Complaint filed by the Insured(s) in this action. . The “home,” “property,” or “insured property” shall refer to the property referenced in the Complaint and its attachments. . The term “policy” shall refer to the insurance policy referenced in the Complaint and its attachments. . The “Date of the Loss” shall refer to the date the insured property sustained the damage for which the Complaint was filed. . The term “representative” as used herein with regard to a person or entity means and includes any natural person, individual, proprietorship, partnership, corporation, association, organization, join venture, firm, other business enterprise, governmentalbody, each and every present and former director, officer, partner, employee, agent, independent consultant or expert or other person (including attorneys), such as friends, relatives and spouse acting or purporting to act on behalf of the person or entity, . “Person(s)” shall refer to a natural person, an individual, firm, association, partnership, joint venture, corporation, trust and estate, or other form of legal or business entity, public or private. “Document(s)” shall refer to and all written recorded, or graphic matter, however produced or reproduced, of every kind and description, hether produced internally or received from outside sources, including without limiting the generality of the foregoing, and all originals, copies, and drafts, of all papers, books, letters, correspondence, memoranda, catalogs, warranties, minutes of meetings, facsimiles transfer lists, shareholder lists, opinion letters, letters of understanding, letters of intent, private placement memoranda, SEC Form 504 Offer Statements, offering statements or circulars, memoranda of telephone conversations, telegrams, photographs, prospectus, drawings, sketches, feasibility studies, interoffice communications, licenses, testing reports, laboratory reports, agreements, ledgers, books of account, summaries, computer print- outs, proposals, suggestions, legal pleadings, bills of sale, indemnity agreements, security notebooks., calendar, appointment books, diaries, agendas, time sheets, log, transaction files, credit reports, notations, notes, minutes of meetings, sound records, photo records, or tale recordings or other data compilations from which information can be obtained, any transcriptions thereof, bulletins, circulars, press releases, notices, instructions, advertisements, work assignments, film videotapes, film negatives, research, articles, treatises, and including all attachments and enclosures thereto. Documents shall also include matters stored in an electronic medium, such matters being, among others, voice mail messages and filed, backup voice mail files, email messages and files, word processing documents, spreadsheets, presentation documents, graphics, animations, images, instant messages and/or instant message logs, backup email files, deleted email data files, program files, backup and archived tapes, temporary files, system history files, website log files, cache files, cookies, and other electronically recorded information. Documents also means all documents of the class requested and includes all documents in the immediate possession and control of the deponent and or all documents that can be obtained from the other persons subject to the direction and control of the deponent, including but not limited to, agents, employees, officers, directors, attorneys, accountants, subcontractors and consultants. Electronic documents shall also include matters described as accurate data, deleted data, backup data, metadata, migrated data, replicate data, residual data, and legacy data. . The term “concerning” means relating to, referring to, describing, evidencing and /or constituting. . The conjunctions “and” and “or” shall be interpreted in every instance as meaning “and/or.”. The term “referring (to)” or “relating (to)” shall mean setting forth, pertaining to, memorializing, constituting, embodying, discussing, analyzing, reflecting, showing, disclosing, averring to, comprising, evidencing, or otherwise concerning. . As herein used, the singular shall include the plural. . The word “any” shall be interpreted as to include the word “all” and the word “all” shall be interpreted as to include the word “any.” The term “communication” shall refer to any transmission of information by any means, including without limitation, by spoken language, electronic transmission of data or any other means, any copies of written information received by the person or entity responding to this request, even if such person or entity is not the primary or direct addressee of such written information. . “Locate” or “location” shall mean to state the present whereabouts of each Document and to identify the persons having possession, custody, or control thereof . “Date” shall mean the exact day, month, and year, if ascertainable, or if not, the best approximation (including relationship in time to other events). Identify, when used in reference to: a. an individual, shall mean to state their full name, present or last known address (designating which) and present or last known employment, position, business affiliation (designating which) including job title and employment address; or such other information sufficient to enable Plaintiff to identify the person; b. an entity, shall mean to state tis full name and preset or last known address (designating which), the legal form of such entity, and the residence address, job title, and business address for its Chief Executive Officer. c. a document, shall mean to state the title (if any), date , author, sender, recipient, type of document, or some other means of identifying it, a summary of its contents and its present location and custodian; d. an oral transaction or oral communication, shall mean to state the date and place thereof, the author and the recipient of the communication, and a sufficient summary of the contents of the communication to indicate the nature and substance. . “Identify,” when used in any context not addressed above, shall mean to describe the act, word, situation, event, conduct, and course of action of any nature whatsoever, including without limitation any failure to act, to engage in any conduct or to pursue any course of action, as fully as possible and identify each way in which said act, word, situation, event, conduct, or course of action was recorded.INSTRUCTIONS A. If any interrogatory requests information about persons that no longer work for you, please provide his/her last known home address and phone number. B. These interrogatories are continuing so as to require the filing of subsequent answers promptly in the event that defendant, by or through any of their agents, counsels or other representatives, learns additional facts relevant to any answers not set forth in their answers to these interrogatories or discovers that any information given in an answer or answers is erroneous. C. For each and every answer to these interrogatories: a. Identify each and every person who participated in supplying information and/or drafting your response or any part thereof; and b. If the answer to any of these interrogatories was made by referring to or reviewing any documents, identify each and every document referred to or reviewed and the interrogatories in connection with which they were used. D. As used in these interrogatories, the singular shall be deemed to include the plural, and the plural to include to the singular, so as to make the interrogatory inclusive rather than exclusive. E. Where an interrogatory contains a general question followed by a specific question, the specific question is to be read and interpreted as requesting additional information, not as limiting the general question. F. Whenever an interrogatory calls for information that is not available to you in the form requested, but which is available in another form or can be obtained at least in part from other data in your possession, so state, and either (a) supply the information requested in the form in which it is available, or (b) supply the data from which the information requested can be obtained. G. If you claim a privilege with respect to information pertaining to any document that you are asked to identify or describe in these interrogatories, furnish a list signed by counsel giving the following information with respect to each such document: a. The title of the documents; b. The nature of the documents, e.g. interoffice memorandum, correspondence, report, etc. c. The identity of the sender and identity of the recipients of the document; d. A statement of the basis from which the privilege is claimed and a summary of the subject matter of the document in sufficient detail to permit the Court to rule on the propriety of the claim of privilege; and e. The paragraph number of the interrogatory to which the document is responsive or otherwise pertains; H. If you contend that it would be unreasonably burdensome to obtain and provide all of the information called for in response to any one of these interrogatories or any subpart thereof, then in response to the appropriate interrogatory or subpart:L a. Set forth all such information that is available to you without undertaking what you contend to be an unreasonable burden; b. State with particularity the grounds on which you contend that additional efforts to obtain such information would be unreasonably burdensome; and c. Describe with particularity the efforts made by you to secure such information, including, without limitation, the identity of all persons consulted, and filed, records, and documents reviewed, and the identity of each person who participated in fathering such information, including the duration of time spent and nature of work done by each person. Interrogatories calling for numerical or chronological information shall be deemed, to the extent that precise figures or dates are not known, to call for estimates. You may, in lieu of identifying any Document or written documentation, attach a true and correct copy of each Document as en exhibit to the answers to these interrogatories. On each occasion in which you choose to attach a Document as your answer to an interrogatory, identify the portion of the Document that answers the interrogatory. . Identify each Document produced pursuant to an interrogatory by the paragraph number of the interrogatory in response to which it is produced and by the file from which the document was produced. If any of the information furnished in an answer to all of part of any interrogatory is not within your personal knowledge, identify each person who has personal knowledge of the information furnished in such answer and each person who communicated to you any part of the information furnished.INTERROGATORIES 1, Identify each person who prepared answers to these interrogatories or supplied and/or provided information to you used to prepare your answers to these interrogatories by stating each person’s name, current business address, telephone number, and relationship to the Defendant. ANSWER: 2. Identify all individuals and/or entities, including the desk adjuster/internal claims adjuster, field adjuster/independent adjuster, forensic engineer, general contractor, examiners, supervisors, and estimators, that have worked on Plaintiff's claim by stating their telephone numbers, current business addresses, and their involvement in Plaintiff's claim. ANSWER:3. Identify all inspections, reviews, and/or investigations that you conducted of the insured property, from the date of loss through the current date, by stating the dates and reasons for the inspections/reviews/investigations, and the names and business address of the persons present. ANSWER: 4. Identify all reports, photographs, or other documents made at each inspection, review, and/or investigation that you conducted of the insured property, from the date of loss through the current date, and state the current location of each said report, photograph, or document. ANSWER:5. If your company’s underwriting department inspected Plaintiffs property as a condition to insuring the property or renewing said insurance, state the names and business addresses of the individuals or entities that performed said inspections and the dates of said inspections. ANSWER: 6. If you prepared a payment letter or explanation of payment to Plaintiff, identify all the documents that you relied upon in preparing said letter. ANSWER:7, Please identify by claim number all claims associated with the loss referenced in the Complaint. ANSWER: 8. Identify, by name, business address, and phone number, each person that is or has been responsible for determining and/or analyzing on your behalf how the policy of insurance that you used for the insured property applies to the claim for coverage at issue in this lawsuit. ANSWER:9. 10. Identify all estimates of damages regarding the insured property, from the effective date of the policy of insurance through the date of your response to this interrogatory request, by specifying the names of all persons who prepared the estimate, the date in which such estimate was prepared, the year of pricing used, the source of pricing, and the reason that the estimate was prepared. ANSWER: Without referring to any court pleading, please state with specificity the basis for all of your affirmative defenses. Please specify all facts and identify with specificity all documents supporting said affirmative defenses. ANSWER:11. Please state with specificity how the amount of depreciation was calculated in the instant matter. Furthermore, please refer to any and all documentation and/or facts which support the amount of depreciation claimed. ANSWER: 12. Please state any condition precedent and any condition subsequent to Plaintiffs claim that you contend have not been fulfilled by the Plaintiff. ANSWER: 13. Defendant claims that Plaintiff failed to submit documents or information, or failed to comply with a request, including requests for reinsertion of the property or for the Plaintiff to submit to a recorded statement. Please state which documents, information, or other request Plaintiff allegedly failed to comply with. For each such request, please state by date and in what form that request was made. ANSWER:JURAT PAGE Dy ene» being duly sworn upon oath, state that the foregoing Answers to Interrogatories are true and correct. STATE OF FLORIDA ) COUNTY OF 5 The foregoing instrument was acknowledged before me, this a cen? 2019 by | known to me or, who has produced ___ and who did take an oath. day of __ who is personally __. a8 identification NOTARY PUBLIC My Commission Expires: